On 2 November 2023, the CSSF issued circular CSSF 23/844 (the "Circular") aiming to clarify the technical details regarding reporting obligations for Alternative Investment Fund Managers (“AIFMs”). The Circular repeals the CSSF circular 14/581.
Reporting obligations of AIFMs
Directive 2011/61/EU of 8 June 2011 on AIFMs (the “AIFMD”) requires, among others, periodical information from the managers concerned at a frequency depending on their assets under management, their investment strategies and their use of leverage.
On 19 December 2012, the European Commission adopted Delegated Regulation (EU) No 231/2013 (the “Regulation”) supplementing the AIFMD which provides details on the reporting obligations. Among others, Annex IV of the Regulation contains a reporting template that AIFMs must use to comply with their reporting obligations.
On 15 November 2013, ESMA published its final report on the ESMA guidelines on AIFMD reporting obligations under Articles 3 and 24 of the AIFMD as well as AIFM reporting XSD schema and samples. Further details and technical supporting material (a consolidated reporting template, detailed IT guidance for filing of the XML and the XSD schema) were also published by ESMA.
This guidance was updated following the implementation in November 2023 of the revised IT technical guidance introduced in ESMA’s AIFMD Reporting Technical Guidance – revision 6.
The Circular requires that the reporting files be submitted according to the specifications detailed in the technical guidance.
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